CAFO Fact Sheet series
Fact Sheet #11: CAFO Requirements for Dairy Barnyards
By Peter Wright, Cornell University
Introduction
Disclaimer
This fact sheet reflects the best professional judgment of the contributing
author and is based on information
available as of the publication date.
Also, your state may have additional,
more stringent requirements than
EPA's requirements. Contact your
permitting authority for complete
information on the regulations that
apply to you.
Copyright © 2003.
MidWest Plan Service,
Iowa State University,
Ames, Iowa 50011-3080.
Copyright Permission
For copyright permission, call MidWest Plan Service (MWPS) at 515294-4337. Organizations may reproduce this fact sheet for noncommercial use, provided they
acknowledge MWPS as the copyright owner and include the following
required credit statement:
In December 2002, EPA released new rules revising and clarifying
the Concentrated Animal Feeding Operation (CAFO) regulations.
They also notified states that these rules need to be implemented.
Producers who in the past may not have known about or responded to CAFO requirements will now need to meet them. This fact
sheet focuses specifically on the barnyard.
Production areas, which include barnyards on dairy farms, were
regulated by the previous CAFO regulations and continue to be
regulated. The “production area” includes the animal confinement
areas (including barnyards), the manure storage area, the raw
materials storage area, and the waste containment area. The new
rules require farm operators, even those who had assumed they
had no discharge from their barnyard, to file with the regulating
agency. Farms that fall under the CAFO rules (see CAFO Fact
Sheet #2: Do I Need an NPDES Permit for My Livestock or
Poultry Operation?) need to apply for a permit and implement a
Nutrient Management Plan (NMP) controlling the runoff from
their barnyard and treating it appropriately. This fact sheet will
provide information about the best way to do this.
Requirements for Dairy Operations
 The Effluent Limitations Guidelines (ELG) for dairy
CAFOs apply only to those operations that have a onetime capacity of 700 mature dairy cows (milked or dry).
More information on the applicability of the new CAFO
regulations can be found in CAFO Fact Sheet #2 of this
series.
 There must be no discharge of manure, litter, or process
from the production area unless certain requirements are
met:
 Rainfall causes the discharge
AND
Reprinted from Livestock and Poultry
Environmental Stewardship
curriculum, fact sheet authored by
Peter Wright, Cornell University,
courtesy of MidWest Plan Service,
Iowa State University, Ames, Iowa,
50011-3080 and your land-grant
universities, Copyright © 2003.
1
October 2003
Requirements for Dairy Operations
(continued)
Pasture vs. Barnyard

The production area is designed,
operated, and maintained to contain all
of the manure, litter, and process wastewater, including storm water plus runoff
from the 25-year, 24-hour rainfall event
AND
 The CAFO is otherwise complying with
the inspection, monitoring, recordkeeping, and mortality disposal provisions in the rule.
Producer Checklist
1. Determine if you are a CAFO (see CAFO Fact
Sheet #2).
2. Determine if you have a barnyard (see the
following section titled Pasture vs. Barnyard).
3. Determine if you would have a discharge during
a 25-year, 24-hour storm.
4. Can the barnyard be:
a. Eliminated?
b. Reduced?
c. Moved?
5. Control outside clean water.
a. From roof areas
b. Surface flow
c. Subsurface flow
d. Overflowing waterers
6. Catch the runoff.
7. Treat the stored runoff appropriately.
Pastures are not regulated by CAFO rules because by
definition a pasture is not a CAFO, since the animals
are not stabled or confined and there is vegetation
and forage growth in the pasture. However, winter
grazing areas where the animals are kept for more
than 45 days and have removed the vegetation may
be considered a CAFO. Denuded areas in a pasture
where animals congregate such as around feeders and
waterers may be considered production areas. Laneways that are bare but are only used to move the
animals to and from pastures are not considered
production areas. Supplying food and water to a
pasture does not make it a CAFO. Commonsense and
sound judgment should be used to distinguish
between a pasture and an abused area that needs to
have the runoff controlled under the CAFO rules.
Sufficient Design Capacity
Under the new regulations, manure and process
wastewater discharges from large dairy CAFOs are
prohibited except when rainfall causes an overflow
from a facility that is designed, maintained, and
operated to contain all manure and process wastewater including storm water plus runoff from the 25year, 24-hour rainfall event.
It may be obvious to you that your barnyard [without
best management practices (BMPs) to catch and store
the runoff] will have a discharge that flows to surface
waters during the 25-year, 24-hour storm event (see
Figure 1). If it is not obvious to you, a hydrologist or
Figure 1. Rainfall from a 25-year, 24-hour storm, in inches. This is a theoretical event that could occur on average
once in a 25-year period and may include an intense short-duration storm for a period less than 24 hours.
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October 2003
engineer can help you determine what will happen
during this large rainfall event. Discharges from dairy
barnyards during storms larger than the 25-year, 24hour storm are allowed to run off but only the portion
that exceeds the 25-year, 24-hour storm. You will
need to install BMPs to control the runoff.
Eliminate the Barnyard
Before the negative environmental consequences
resulting from having a barnyard were well understood, there were a number of good reasons for
barnyards to be installed or allowed on dairy farms.
However, now that the environmental impacts are
more defined and the regulations for CAFO permits
require control of this runoff, it may make more
sense for the farm operator to eliminate the barnyard
and house the dairy animals either in a barn or on a
pasture system without allowing them to use a barnyard.
Past uses for a barnyard included as a holding area
while the barn was being cleaned or before the cows
were milked. These areas were generally small and
could be roofed. Some farms used outside lots to
provide supplemental feed to the animals. However,
using total mixed rations reduces the need for barnyards to be used as feeding areas. The feed preserves
its nutrition and energy levels best when kept under a
roof to avoid being overheated by the sun or soaked
by the rain. Restricting access to the feed to when the
cows are outside can also lower dry matter intake.
Using outside barnyards as resting areas for the cows
is an indication that cow comfort in the barn stalls is
not adequate for maximum production.
Cows do not benefit from exercise in the barnyard;
studies examining exercise impacts on cows
generally start at 2 miles per day.
barnyard before spending money on controlling the
runoff from it.
Reduce or Move the Barnyard
Planning the location and size of barnyards can reduce the pollution potential. Furthermore, lowering
the pollution potential to desired levels costs less in
properly located and sized barnyards. Many of the
problems of diverting or controlling outside surface
water and catching and treating dirty barnyard runoff
can be reduced or eliminated by locating the barnyard
in the right place. Moving existing barnyards to
higher ground, away from a stream, or away from the
drip edge of a roof can help prevent pollution while
avoiding the increased costs that outside water
control systems would require.
The size of existing and proposed barnyards should
be evaluated to eliminate the cost of extra concrete
placement and the environmental effect of too large
of an abuse area. Table 1 shows the recommended
size for barnyards. Smaller sizes will stress the
animals.
Table 1. Barnyard sizes, in square feet
Feeder Cattle or Heifers
Using an outside area for heat detection is not needed
if the cows have access to each other in a freestall
and have traction to exhibit mounting behavior. Even
without freestalls, secondary signs of heat detection
such as milk reduction, discharges, and behavior
changes can be used to identify cows to breed.
Synchronized ovulation can be used at a cost of about
$8/cow. Every effort should be made to eliminate the
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Finishing
Cows
400-800
lbs
800-1,200
lbs
1,300
lbs
150-300
250-500
300-500
20-25
30-35
40-45
200-600
400-800
500-800
40-50
50-60
60-75
Lot Space
Unpaved lot
with mound
(includes
mound space)
Mound Space
Providing outside access to overcome poor barn
ventilation might be better dealt with by improving
barn ventilation. Hoof health concerns raised when
cows are always on concrete can also be dealt with
by improving the surfaces that they walk on in the
barn. Hoof problems and mastitis are some of the
health risks associated with dirty barnyards.
Calves
Unpaved Lot
without Mound
Paved Lot
From Beef Housing and Equipment Handbook.
Keeping the Clean Water Clean
Extra water from barn roofs, overflowing waterers,
and/or uphill overland flow can increase the potential
of pollutant runoff. Barnyards that are adjacent to or
even include a stream or a depression can create
significant environmental problems. Barnyards over
sized for the number of cattle they contain add to the
runoff problems without improving the operation.
Barnyards that are not cleaned or can only be poorly
cleaned leave contaminants exposed on the surface
that will wash away later.
October 2003
Keeping the clean water clean is vital to good barnyard management. A continuously leaking waterer
will carry pollutants to a filter area and then ruin the
sod's ability to filter the pollutants by constantly wetting the vegetation. Grass will not remain healthy if it
is constantly exposed to dirty water without a rest
period. Maintaining waterers so that they do not overflow is part of good barnyard management.
Roof water can be controlled by using rain gutters
or drip trenches. Because barn roofs are much larger
than most roofs, the rain gutters and downspouts need
to be designed to carry the amount of water these
large areas can provide. The size of the gutters, their
slope, and the placement and size of the downspouts
all depend on the amount of rain water to be carried.
The 10-year, 5-minute storm is a common design
storm for rain gutters. The gutters also need to be
protected against snow and ice damage. Hanging
them lower than the projected roofline prevents snow
and ice from sliding off barn roofs and knocking the
gutters down. Extra hangers for the gutters, as closely
spaced as 16 inches, or ice-breaking obstacles on the
roof that stop sliding snow are often required to protect the gutters and keep them working properly.
Drip trenches that collect falling roof water and direct
it to a ditch or tile to be carried away from the barnyard are often longer lasting and cheaper than roof
gutters. A gravel trench with a tile line is placed
under the drip line of the roof. To avoid contaminating the clean water with manure, the drip trench
needs to be fenced out of the barnyard.
Diversions, berms, or land grading can prevent uphill
surface flow from running through the barnyard. Tile
inlets with small storage structures can be used when
the surface water cannot be easily moved around the
barnyard. Subsurface drainage should be used to prevent ground water from surfacing in the barnyard,
adding to the contaminated runoff water. These
structures should be designed according to Natural
Resource Conservation Service (NRCS) standards
by a competent conservation contractor, a Soil and
Water Conservation District (SWCD) or NRCS
employee, or an agricultural engineer.
Catch the Runoff
Barnyard paving should be planned to control the
runoff and urine flow. To facilitate scraping, curbs
are needed around all concrete areas. A corner of the
barnyard with higher curbs should be graded lower,
making the liquids flow to it. This shallow storage
area can contain urine and low flows until the barnyard is cleaned. Mixing the rest of the manure with
this liquid should enable it to be picked up and
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spread, limiting runoff to large storm events. The
runoff from large events may be directed to properly
designed filter areas, constructed wetland systems, or
storage systems for later land application. These runoff collection systems need to be designed to handle
the manure solids that accompany the runoff water.
Small holes in the curbs or more sophisticated solid
retention systems should be used to keep most of the
solids on the paved pad for future cleaning and
spreading. Picket dams of treated two by sixes set upright three fourths of an inch apart can help to retain
the solids. These picket dams can be followed by a
one-half-inch and then a quarter-inch screen in series
to sort out finer and finer solids. Although these
screens will require cleaning after each runoff event,
they provide a positive solid trap that reduces the
loading on downstream collection or treatment
systems.
Storage ponds need to be big enough to collect the
runoff flowing from all areas of the barnyard for
events up to a 25-year, 24-hour storm. If clean water
diversion systems are not installed or do not catch the
25-year, 24-hour storm, that water needs to be included. The storage areas need to be sized to include
the manure washed off the barnyard, solids that were
not removed, and any past runoff that was not treated
or land applied before the next storm event. The soils
at the storage site need to be evaluated and/or modified to prevent polluted water from moving into the
ground. On some sites, these storage areas may need
to be lined.
Inspections
Manure storage sites need to be maintained and
monitored. The operators of large CAFOs (with more
than 700 cows or 1,000 heifers) are required to perform weekly inspections of all storm water diversion
devices, runoff collection structures, waste storage
structures, and manure or runoff transporting
systems. To prevent inadvertent overflows onto barnyards or into storage areas, water lines need to be
inspected daily. Depth markers or staff gauges need
to be installed (see CAFO Fact Sheet #15: Liquid
Level Markers for . . .) in the storage areas to determine the amount of storage volume remaining, ensuring that a 25-year, 24-hour storm will not over-top
the structure and that there is adequate freeboard.
Any deficiencies or discharges need to be recorded
and then addressed as soon as possible. In addition,
mortalities must be kept from the wastewater system.
The dairy farm operator must keep a complete copy
of these records for the last five years (see CAFO
Fact Sheet #6: What CAFO Reports Must I Submit?).
October 2003
Treat the Runoff Appropriately
Manure and wastewater caught from a barnyard need
to be either treated or applied at agronomic rates to
cropland. CAFO Fact Sheet #20: What is Required in
a Nutrient Management Plan? describes this process.
The nutrient contents of barnyard runoff may vary
considerably so multiple samples may be needed to
determine the appropriate loading rates. Wastewater
can be treated in vegetated filter areas, constructed
wetlands, or other treatment systems. These systems
must be designed to prevent the varying concentrations and volumes of barnyard runoff from causing
pollution.
Is Cost Sharing Available?
Through government programs, USDA-NRCS has
allocated some money that may be used to cost share
the BMPs needed to correctly handle barnyard runoff. Check with your local NRCS, SWCD, or
Environmental agency to see what funds are available
and if you qualify. CAFO Fact Sheet #40: Financial
and Technical Assistance Available to CAFO
Owners/Operators will help you identify cost share
programs for which you may be eligible.
farm operators must consider when dealing with their
barnyard discharges.
Definition of Terms
Barnyard–Areas where cattle are confined for more
than 45 days during the year without vegetated cover.
Part of the “production area” covered under the
CAFO regulations.
BMPs–Best Management Practices. Practices that
help prevent pollution. Often have standards developed by the Natural Resources Conservation Service.
CAFO–Concentrated Animal Feeding Operation.
Farms that by definition are point sources and need
regulating according to the Federal Government.
Drip trench–A system of channels and berms that
collects roof water at the base of the roof, preventing
clean water from entering a barnyard and polluted
water from the barnyard from mixing with the clean
roof runoff.
Laneways–Non-vegetated areas in a pasture system
that are used only for cattle movement to pastures.
Time Line for Compliance with Production
Area Provisions of the New CAFO Rule
The time line for compliance with the new rules is
fairly complex. Some provisions took effect upon
adoption of the rule in December 2002; others do not
take effect until the year 2006. CAFO Fact Sheet #3:
How Soon Must I Apply for an NPDES Permit? details these compliance deadlines and provides a
means for you to determine what deadlines your
CAFO faces.
Supporting Sections
40 CFR Part 412.30-47 Effluent Limitations
Guidelines–Concentrated Animal Feeding Operations
(CAFO) Point Source Category.
 Subpart C: Dairy Cows and Cattle Other
Than Veal Calves
Summary
Barnyards on dairy farms have previously been regulated by federal CAFO regulations and continue to
be regulated by a small number of changes adopted in
April 2003. Existing dairy farm CAFO operators who
fall under the CAFO rules (see CAFO Fact Sheet #2)
need to apply for a permit and implement an NMP by
December 31, 2006, controlling the runoff from their
barnyard and treating it appropriately. States may
have additional, more stringent requirements. This
fact sheet provided an outline of issues that dairy
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NMP–Nutrient Management Plan. A plan that considers the source and fate of nutrients on the farm and
is designed to minimize nutrient losses to the
environment.
Pasture–An area where vegetation exists for cattle
feed. It is not generally considered part of a CAFO.
Vegetated filter area–A system designed to prevent
pollution by treating diluted wastewater through flow
into a vegetated area.
Author
Peter Wright, a Manure Management Specialist at
Cornell University, can be reached at
pew2@cornell.edu.
Reviewers
The author wishes to thank Dana Chapman,
Agricultural Consulting Service, and Lee Telega,
PRO-DAIRY, for their review of this fact sheet.
October 2003
For More Information
State Contacts
EPA CAFO Phone Line
Nebraska
Iowa
Missouri
National and Regional
202-564-0766
202-564-0766
202-564-0766
202-564-0766
http://www.oznet.ksu.edu/
kcare/
http://extension.agron.iastate
.edu/immag/
http://outreach.missouri.edu/mo
mmag/
http://www.epa.gov/npdes
/caforule/–To obtain copy
of regulations
Gary Buttermore
John Harsch
Gene Tinker
Randy Kixmiller
Ralph Summers
(402)-471-4255
(785) 296-0075
(515) 281-3103
(573) 751-6568
(913) 551-7418
gary.Buttermore@ndeq.state.ne.us
jharsch@kdhe.state.ks.us
gene.tinker@dnr.state.ia.us
nrkixmr@dnr.state.mo.us
summers.ralph@epa.gov
Rick Koelsch
Joel DeRouchey
John Lawrence
John Lory
State Cooperative
Extension contacts
402-472-4051
(785) 532-2280
(515) 294-6290
(573) 884-7815
rkoelsch1@unl.edu
jderouch@oznet.ksu.edu
jdlaw@iastate.edu
LoryJ@missouri.edu
Mike Kucera
Lyle Frees
Chris Murray
Troy Chockley
(402) 471-4102
(785) 823-4553
(515) 284-4370
573-876-9394
Michael.Kucera@ne.usda.gov
lyle.frees@ks.usda.gov
chris.murray@ia.usda.gov
troy.chockley@mo.usda.gov
Educational Resources
http://www.lpes/
http://www.lpes/
http://www.lpes/
http://www.lpes/
http://www.lpes/
USDA Farm Bill Resources
http://farmbill.unl.edu/
See national site
See national site
See national site
http://www.nrcs.usda.gov/
programs/farmbill/2002/
Environmental Regulations
Related Resources
State Environmental
Regulatory Agency
State Cooperative Extension
State Natural Resources
Conservation Service
(NRCS)
202-564-0766
Kansas
http://manure.edu.edu
http://cnmp.unl.edu
The LPES educational materials were developed with
support from the USDA-CSREES, the U.S. EPA’s National
Agriculture Compliance Assistance Center, and the
University of Nebraska Cooperative Extension at Lincoln,
under Cooperative Agreement Number 97-EXCA-3-0642.
6
http://www.reeusda.gov/1
700/statepartners/usa.htm/
MWPS (MidWest Plan Service), headquartered at Iowa State
University, is the primary distributor of LPES curriculum materials. To
order the materials on-line, access their website at
http://www.mwpshq.org and visit the catalog section. Discounts are
offered on LPES materials.
October 2003